AS I SEE IT: Streamline and Implement COVID-19 Vaccination Tracking Requirements

AS I SEE IT


Streamline and Implement COVID-19 Vaccination Tracking Requirements

Advice for achieving and maintaining compliance

The Centers for Medicare & Medicaid Services (CMS) recently released updated guidance on how to comply with COVID-19 Vaccination Requirements for Health Care Providers and Suppliers. This new Conditions for Coverage (CfC) requirement can be found under 42 CFR §416.51(c) Conditions for coverage - Infection control; Standard: COVID-19 vaccination of staff. All ASCs that participate in Medicare and Medicaid must have policies and procedures in place to meet three basic requirements. First, all eligible staff must be vaccinated. Second, there must be a process in place to address exemptions and accommodations must be in place for those who are exempt. Finally, there must be a process for securely documenting and tracking vaccination status. Failure to comply with these new CMS regulations for staff vaccination tracking can result in a standard-level violation, condition-level deficiency or even an immediate jeopardy and may impact accreditation status.

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